Tristan Grimbert
Tristan Grimbert President and CEO EDF Renewables 15445 Innovation Drive San Diego, CA 92128
October 20, 2017
Dear Mr. Grimbert: I am writing again to express American Bird Conservancy’s (ABC’s) serious concern over EDF Renewable’s proposed Vista Mountain Wind Power Project in the sensitive Texas Hill Country/Cross Timbers region (in Hamilton, Coryell, Lampasas and Mills Counties) and associated high voltage lines and towers to connect it to the existing grid. This is the second letter we have written; the purpose of this correspondence is to point out some additional concerns. ABC is a 501(c) (3) not-for-profit membership organization whose mission is to conserve native birds and their habitats throughout the Americas (www.abcbirds.org). ABC acts by safeguarding the rarest species, conserving and restoring habitats, and reducing threats, while building capacity in the bird conservation movement. ABC is a proponent of Bird Smart Wind Energy, which is described in some detail in Hutchins et al. (2016). Careful wind generation siting is crucial in preventing unintended impacts to native bird and bat species. ABC is concerned that the proposed Vista Mountain Wind Power Project and its associated power lines and towers pose an unacceptably high risk to protected U.S. wildlife. This is especially true, as we have become aware that there are other proposed and existing wind energy facilities in this ecologically sensitive area, including the Priddy, Goldthwaite and Flattop Wind Energy Projects . As such, the cumulative impact of any future development on wildlife becomes an important issue. As you may know, the National Environmental Policy Act (NEPA) requires that cumulative impacts are taken into consideration during pre-construction risk assessments. This argues for a full-blown Environmental Impact Statement (EIS), not a cursory Environmental Assessment (EA). The presence of Threatened and Endangered species in the area, such as the Whooping Crane, are also of great concern to us as a bird conservation organization. We recently conducted a study of Whooping Crane stopover sites (Moore et al, 2017), overlaying them with existing and proposed wind turbines and power lines and towers. The current siting of wind turbines probably poses limited threat to this species; however, the power lines and towers are another story. Collisions with power lines and towers are a major killer of cranes worldwide (Morkill and Anderson, 1991, Janss and Ferrer 2000, Sundar and Choudhury 2005, Shaw et al. 2010, Stehn and Wassenich, 2008, Wright et al. 2009). Thus, the new power lines and towers you proposed to connect your facility to the existing grid may increase the risk to this species in its Migratory Corridor. Subsequently, approval of this project will require Section 7 consultation under the Endangered Species Act and a full-blown Environmental Impact Statement (EIS). This should be based on at least three years of pre-construction risk studies, all of which should be done by independent experts (not paid consultants to the industry) using standardized methods. Thank you for your consideration of ABC’s views. ABC will be watching this proposed project and reviewing any risk assessments produced very carefully.
1
Sincerely,
Michael Hutchins, Ph.D. Director, Bird-Smart Wind Energy Campaign Cc: T.P. Medlock, S. Williams, J. Manning, S. Walker, B. Roundtree, M. Tines, J.E. Firth, W. Boultinghouse, K.A. Fulk, B. Dosa, C. Harper, J. Ford, K. Mote, J.D. Sheffield, S. Cosper, D. Buckingham References Janss G.F.E., and Ferrer M. 2000. Common crane and great bustard collision with power lines: Collision rate and risk exposure. Wildlife Society Bulletin 28:675–680. Moore, D., Lacy, A. Hutchins, M. and Parr, M. 2017. Whooping Crane Migration Stopover Habitat Assessment Tool for Wind Energy and Power Line Development. Baraboo, WI and Washington, DC: International Crane Foundation and American Bird Conservancy. Morkill, A.E., and Anderson, S.H. 1991. Effectiveness of markers in reducing Sandhill Crane collisions with powerlines. Wildlife Society Bulletin 19: 442-49. Shaw J.M., Jenkins A.R., Smallie, J.J., Ryan, P.G. 2010. Modelling power-line collision risk for the Blue Crane Anthropoides paradiseus in South Africa. Ibis 152:590–599. Stehn T., and Wassenich, T. 2008. Whooping Crane collisions with power lines: An issue paper. Proceedings North American Crane Workshop 10:35–36. Sundar, K.S.G., and Choudhury, B.C. 2005. Mortality of Sarus Cranes (Grus antigone) due to electricity wires in Uttar Pradesh, India. Environmental Conservation 32:260–269. Wright, G.E., Smith, T.J., Murphy, R.K., Runge, J.T., and Harms, R.R. 2009. Mortality of cranes (Gruidae) associated with powerlines over a major roost on the Platte River, Nebraska. Prairie Naturalist 41:116– 120.
2
October 20, 2017
Dear Mr. Grimbert: I am writing again to express American Bird Conservancy’s (ABC’s) serious concern over EDF Renewable’s proposed Vista Mountain Wind Power Project in the sensitive Texas Hill Country/Cross Timbers region (in Hamilton, Coryell, Lampasas and Mills Counties) and associated high voltage lines and towers to connect it to the existing grid. This is the second letter we have written; the purpose of this correspondence is to point out some additional concerns. ABC is a 501(c) (3) not-for-profit membership organization whose mission is to conserve native birds and their habitats throughout the Americas (www.abcbirds.org). ABC acts by safeguarding the rarest species, conserving and restoring habitats, and reducing threats, while building capacity in the bird conservation movement. ABC is a proponent of Bird Smart Wind Energy, which is described in some detail in Hutchins et al. (2016). Careful wind generation siting is crucial in preventing unintended impacts to native bird and bat species. ABC is concerned that the proposed Vista Mountain Wind Power Project and its associated power lines and towers pose an unacceptably high risk to protected U.S. wildlife. This is especially true, as we have become aware that there are other proposed and existing wind energy facilities in this ecologically sensitive area, including the Priddy, Goldthwaite and Flattop Wind Energy Projects . As such, the cumulative impact of any future development on wildlife becomes an important issue. As you may know, the National Environmental Policy Act (NEPA) requires that cumulative impacts are taken into consideration during pre-construction risk assessments. This argues for a full-blown Environmental Impact Statement (EIS), not a cursory Environmental Assessment (EA). The presence of Threatened and Endangered species in the area, such as the Whooping Crane, are also of great concern to us as a bird conservation organization. We recently conducted a study of Whooping Crane stopover sites (Moore et al, 2017), overlaying them with existing and proposed wind turbines and power lines and towers. The current siting of wind turbines probably poses limited threat to this species; however, the power lines and towers are another story. Collisions with power lines and towers are a major killer of cranes worldwide (Morkill and Anderson, 1991, Janss and Ferrer 2000, Sundar and Choudhury 2005, Shaw et al. 2010, Stehn and Wassenich, 2008, Wright et al. 2009). Thus, the new power lines and towers you proposed to connect your facility to the existing grid may increase the risk to this species in its Migratory Corridor. Subsequently, approval of this project will require Section 7 consultation under the Endangered Species Act and a full-blown Environmental Impact Statement (EIS). This should be based on at least three years of pre-construction risk studies, all of which should be done by independent experts (not paid consultants to the industry) using standardized methods. Thank you for your consideration of ABC’s views. ABC will be watching this proposed project and reviewing any risk assessments produced very carefully.
1
Sincerely,
Michael Hutchins, Ph.D. Director, Bird-Smart Wind Energy Campaign Cc: T.P. Medlock, S. Williams, J. Manning, S. Walker, B. Roundtree, M. Tines, J.E. Firth, W. Boultinghouse, K.A. Fulk, B. Dosa, C. Harper, J. Ford, K. Mote, J.D. Sheffield, S. Cosper, D. Buckingham References Janss G.F.E., and Ferrer M. 2000. Common crane and great bustard collision with power lines: Collision rate and risk exposure. Wildlife Society Bulletin 28:675–680. Moore, D., Lacy, A. Hutchins, M. and Parr, M. 2017. Whooping Crane Migration Stopover Habitat Assessment Tool for Wind Energy and Power Line Development. Baraboo, WI and Washington, DC: International Crane Foundation and American Bird Conservancy. Morkill, A.E., and Anderson, S.H. 1991. Effectiveness of markers in reducing Sandhill Crane collisions with powerlines. Wildlife Society Bulletin 19: 442-49. Shaw J.M., Jenkins A.R., Smallie, J.J., Ryan, P.G. 2010. Modelling power-line collision risk for the Blue Crane Anthropoides paradiseus in South Africa. Ibis 152:590–599. Stehn T., and Wassenich, T. 2008. Whooping Crane collisions with power lines: An issue paper. Proceedings North American Crane Workshop 10:35–36. Sundar, K.S.G., and Choudhury, B.C. 2005. Mortality of Sarus Cranes (Grus antigone) due to electricity wires in Uttar Pradesh, India. Environmental Conservation 32:260–269. Wright, G.E., Smith, T.J., Murphy, R.K., Runge, J.T., and Harms, R.R. 2009. Mortality of cranes (Gruidae) associated with powerlines over a major roost on the Platte River, Nebraska. Prairie Naturalist 41:116– 120.
2
